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Year Deficiency
1988 $88,979
1989 18,979
1990 1,330
The issues remaining for decision are:
(1) Are petitioners Ronald Gordon (Mr. Gordon) and Beverly
Gordon (Ms. Gordon) entitled to a net operating loss deduction
for 1988 that is attributable to an alleged net operating loss
carryover from their taxable year 1986? We hold that they are
not.
(2) Is respondent equitably estopped from claiming that
petitioners are not entitled to a net operating loss deduction
for 1988? We hold that she is not.
(3) Is Ms. Gordon entitled to innocent spouse relief under
section 6013(e)(1)2 with respect to the understatement of tax for
1988 that is attributable to the net operating loss deduction
that petitioners claimed for that year? We hold that she is not.
FINDINGS OF FACT
Most of the facts have been stipulated and are so found.
Mr. Gordon and Ms. Gordon resided in New York, New York, at
1 (...continued)
petitioners, each of whom filed a separate petition with the
Court. The two cases were consolidated for purposes of trial and
opinion, but not for purposes of briefing.
2 All section references are to the Internal Revenue Code (Code)
in effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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